Opinion
6606-20
09-27-2021
Ronelle Maree Halfacre Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
MAURICE B. FOLEY CHIEF JUDGE
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction, filed September 16, 2020, on the ground that no notice of deficiency or notice of determination under I.R.C. section 6320 or 6330 was issued to petitioner for tax years 2000 through 2019 in such time that would confer jurisdiction upon the Court in this case. Although the Court directed petitioner to file an Objection, if any, to respondent's motion to dismiss, petitioner failed to do so.
Taking into account representations contained in the petition, and for the reasons set forth in respondent's motion, it is, ORDERED that respondent's motion is granted. It is further
ORDERED that with respect to each year placed in issue in the petition, this case is dismissed for lack of jurisdiction upon the ground stated in respondent's motion.
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